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338 results for “disallowance”+ Section 56(2)(x)clear

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Delhi1,097Mumbai1,077Bangalore338Ahmedabad288Chennai282Kolkata201Jaipur200Chandigarh121Pune113Hyderabad109Cochin90Indore87Nagpur74Agra70Raipur65Surat55Guwahati49Cuttack43Lucknow37Calcutta36Rajkot35Jodhpur19Amritsar17Karnataka16Visakhapatnam15Telangana9Allahabad8Ranchi8SC7Patna6Varanasi6Kerala5Panaji4Dehradun4Himachal Pradesh3Jabalpur2Punjab & Haryana1Rajasthan1Orissa1

Key Topics

Addition to Income71Section 143(3)50Section 14A50Disallowance38Deduction30Transfer Pricing30Section 92C28Section 153A26Section 10A25Section 132

SRI. RAVI SHANKAR SHETTY,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE- 6(3)(1), BANGALORE

In the result, the appeal of the assessee is allowed

ITA 28/BANG/2020[2015-16]Status: DisposedITAT Bangalore08 Oct 2020AY 2015-16

Bench: Shri Chandra Poojari, Am & Smt. Beena Pillai , Jm Ita No.28 /Bang/2020 Assessment Year: 2015-16 Shri Ravi Shankar Shetty, Vs. The Assistant Commissioner Of #289, 1St Floor, 15Th Main, Rmv Income-Tax, Circle-6(3)(1), Extension, Bengaluru Bengaluru-560 080. [Pan:Asups 9568B]

Section 234ASection 56(2)(ix)

X of the procurement agreement gives the parties the right to sue each other for specific performance of the agreement. The Ld. CIT(A) observed that out of the amount of Rs.21,11,00,000/- received from M/s. Metro Corp and Metro Corp Infrastructure Ltd., only an amount of Rs.5,53,81,059/- was given by the assessee as advances

DAKSHINA KANNADA NIRMITHI KENDRA ,MANGALURU vs. INCOME TAX OFFICER, WARD 1(1),, MANGALURU

In the result, all appeals filed by the assessees in all the assessees’ appeals are dismissed except for assessment year

Showing 1–20 of 338 · Page 1 of 17

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20
Comparables/TP20
Section 234B19
ITA 2087/BANG/2018[2011-12]Status: DisposedITAT Bangalore16 Jun 2022AY 2011-12

Bench: Shri Chandra Poojari & Shri George George K.Assessment Year: 2013-14

For Appellant: Shri Tata Krishna, A.RFor Respondent: Smt. Priyadarshini Basaganni, D.R
Section 11Section 143(2)Section 2Section 2(15)

section 11 of the IT Act cannot be denied by invoking 1st proviso to section 2 (15) if the primary/ dominant objects are not (a) in the nature of trade, commerce or business; or (b) rendering any service in relation to any trade, commerce or business. 4.29 It is reiterated that the Assessee’s main objects do not involve carrying

M/S. UDUPI NIRMITHI KENDRA,UDUPI vs. ASSISTANT COMMISSIONER OF INCOME TAX, (EXEMPTIONS) CIRCLE-1, MANGALORE

In the result, all appeals filed by the assessees in all the assessees’ appeals are dismissed except for assessment year

ITA 1962/BANG/2018[2013-14]Status: DisposedITAT Bangalore16 Jun 2022AY 2013-14

Bench: Shri Chandra Poojari & Shri George George K.Assessment Year: 2013-14

For Appellant: Shri Tata Krishna, A.RFor Respondent: Smt. Priyadarshini Basaganni, D.R
Section 11Section 143(2)Section 2Section 2(15)

section 11 of the IT Act cannot be denied by invoking 1st proviso to section 2 (15) if the primary/ dominant objects are not (a) in the nature of trade, commerce or business; or (b) rendering any service in relation to any trade, commerce or business. 4.29 It is reiterated that the Assessee’s main objects do not involve carrying

DAKSHINA KANNADA NIRMITHI KENDRA ,MANGALURU vs. INCOME TAX OFFICER, WARD 1(1),, MANGALURU

In the result, all appeals filed by the assessees in all the assessees’ appeals are dismissed except for assessment year

ITA 2086/BANG/2018[2010-11]Status: DisposedITAT Bangalore16 Jun 2022AY 2010-11

Bench: Shri Chandra Poojari & Shri George George K.Assessment Year: 2013-14

For Appellant: Shri Tata Krishna, A.RFor Respondent: Smt. Priyadarshini Basaganni, D.R
Section 11Section 143(2)Section 2Section 2(15)

section 11 of the IT Act cannot be denied by invoking 1st proviso to section 2 (15) if the primary/ dominant objects are not (a) in the nature of trade, commerce or business; or (b) rendering any service in relation to any trade, commerce or business. 4.29 It is reiterated that the Assessee’s main objects do not involve carrying

M/S. DAKSHINA KANNADA NIRMITHI KENDRA,MANGALURU vs. THE DEPUTY COMMISSIONER OF INCOME TAX (EXEMPTIONS), CIRCLE -1, MANGALURU

In the result, all appeals filed by the assessees in all the assessees’ appeals are dismissed except for assessment year

ITA 948/BANG/2019[2016-17]Status: DisposedITAT Bangalore16 Jun 2022AY 2016-17

Bench: Shri Chandra Poojari & Shri George George K.Assessment Year: 2013-14

For Appellant: Shri Tata Krishna, A.RFor Respondent: Smt. Priyadarshini Basaganni, D.R
Section 11Section 143(2)Section 2Section 2(15)

section 11 of the IT Act cannot be denied by invoking 1st proviso to section 2 (15) if the primary/ dominant objects are not (a) in the nature of trade, commerce or business; or (b) rendering any service in relation to any trade, commerce or business. 4.29 It is reiterated that the Assessee’s main objects do not involve carrying

DAKSHINA KANNADA NIRMITHI KENDRA ,MANGALURU vs. INCOME TAX OFFICER, WARD 1(1),, MANGALURU

In the result, all appeals filed by the assessees in all the assessees’ appeals are dismissed except for assessment year

ITA 2088/BANG/2018[2012-13]Status: DisposedITAT Bangalore16 Jun 2022AY 2012-13

Bench: Shri Chandra Poojari & Shri George George K.Assessment Year: 2013-14

For Appellant: Shri Tata Krishna, A.RFor Respondent: Smt. Priyadarshini Basaganni, D.R
Section 11Section 143(2)Section 2Section 2(15)

section 11 of the IT Act cannot be denied by invoking 1st proviso to section 2 (15) if the primary/ dominant objects are not (a) in the nature of trade, commerce or business; or (b) rendering any service in relation to any trade, commerce or business. 4.29 It is reiterated that the Assessee’s main objects do not involve carrying

M/S. UDUPI NIRMITHI KEDRA,UDUPI vs. THE DEPUTY COMMISSIONER OF INCOME TAX (EXEMPTIONS), CIRCLE - 1, MANGALURU

In the result, all appeals filed by the assessees in all the assessees’ appeals are dismissed except for assessment year

ITA 947/BANG/2019[2016-17]Status: DisposedITAT Bangalore16 Jun 2022AY 2016-17

Bench: Shri Chandra Poojari & Shri George George K.Assessment Year: 2013-14

For Appellant: Shri Tata Krishna, A.RFor Respondent: Smt. Priyadarshini Basaganni, D.R
Section 11Section 143(2)Section 2Section 2(15)

section 11 of the IT Act cannot be denied by invoking 1st proviso to section 2 (15) if the primary/ dominant objects are not (a) in the nature of trade, commerce or business; or (b) rendering any service in relation to any trade, commerce or business. 4.29 It is reiterated that the Assessee’s main objects do not involve carrying

DAKSHINA KANNADA NIRMITHI KENDRA ,MANGALURU vs. ASSISTANT COMMISSIONER OF INCOME TAX, (EXEMPTIONS), CIRCLE-1,, MANGALURU

In the result, all appeals filed by the assessees in all the assessees’ appeals are dismissed except for assessment year

ITA 2089/BANG/2018[2013-14]Status: DisposedITAT Bangalore16 Jun 2022AY 2013-14

Bench: Shri Chandra Poojari & Shri George George K.Assessment Year: 2013-14

For Appellant: Shri Tata Krishna, A.RFor Respondent: Smt. Priyadarshini Basaganni, D.R
Section 11Section 143(2)Section 2Section 2(15)

section 11 of the IT Act cannot be denied by invoking 1st proviso to section 2 (15) if the primary/ dominant objects are not (a) in the nature of trade, commerce or business; or (b) rendering any service in relation to any trade, commerce or business. 4.29 It is reiterated that the Assessee’s main objects do not involve carrying

M/S INFOSYS LIMITED,BANGALORE vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-3(1)(1), BANGALORE

In the result, the appeal filed by the assessee stands partly allowed

ITA 718/BANG/2017[2012-13]Status: DisposedITAT Bangalore28 Nov 2022AY 2012-13

Bench: Shri Chandra Poojaria & Smt. Beena Pillaiassessment Appeal No. Appellant Respondent Year M/S. Infosys Ltd., The Assistant Electronic City, Commissioner It(Tp)A No. Hosur Road, Of Income Tax, 2012-13 718/Bang/2017 Bangalore – 560 Circle – 100. 3(1)(1), Pan: Bangalore. Aaaci4798L : Shri Padamchand Khincha, Assessee By Ca : Shri K.V. Arvind & Shri Dilip, Revenue By Standing Counsels For Dept. Date Of Hearing : 15-09-2022 Date Of Pronouncement : 28-11-2022 Order Per Beena Pillaipresent Appeal Arises Out Of Final Assessment Order Dated 28/02/2017 Passed By The Ld.Acit, Circle – 3(1)(1), Bangalore For A.Y. 2012-13 On Following Grounds Of Appeal: General & Legal Grounds 1. The Order Passed By The Learned Assessing Officer & The Directions Of Hon’Ble Drp To The Extent Prejudicial To The Appellant Is Bad In Law & Liable To Be Quashed. Grounds On Denial Of Deduction Claimed Under Section 10Aa In Respect Of 4 Sez Units Viz., Chennai – Unit 1, Chandigarh, Mangalore - Unit 1 & Pune Unit 1 2. The Learned Assessing Officer Has Erred In Denying Deduction Claimed Under Section 10Aa In The Return Of Income Totally Amounting To Rs. 2227,82,65,630 In Respect

Section 10ASection 14ASection 2Section 2(24)Section 40

X is not included in the definition of ‘income’ u/s 2(24) or under Chapter IV of the IT Act, 1961. The orders passed by the lower authorities are therefore bad in law and liable to be quashed. 8. The learned assessing officer and transfer pricing officer have erred in making a transfer pricing adjustment

WRITEMEN MEDIA PRIVATE LIMITED,BENGALURU vs. INCOME TAX OFFICER,WARD-7(1)(3), BENGALURU

In the result, appeal filed by the assessee is allowed for statistical purposes

ITA 1516/BANG/2024[2014-15]Status: DisposedITAT Bangalore31 Jul 2025AY 2014-15

Bench: Shri. Laxmi Prasad Sahu & Shri. Keshav Dubeyassessment Year : 2014-15

For Appellant: Shri. Ravishankar, AdvocateFor Respondent: Shri. Ashwin D Gowda, Addl. CIT(DR)(ITAT), Bangalore
Section 115JSection 143(3)Section 153Section 56(2)(viib)

x. The learned authorities below placed reliance on the judgement of Hon’ble Court in the case of Agra Portfolio Pvt Ltd Vs ITO Ward 1(4), New Delhi in ITA No. 2189/De/2018 dated 16.05.2018, however, the learned authorities below failed to appreciate the fact that the Hon’ble High Court of Delhi has recently passed a judgement

RAITHARA ARECANUT MARKETING AND PROCESSING CO-OPERATIVE SOCIETY LIMITED ,BHADRAVATHI vs. INCOME TAX OFFICER, WARD-1 AND TPS, SHIMOGA

In the result, the appeal of the assessee stands allowed for statistical purpose

ITA 1775/BANG/2024[2020-21]Status: DisposedITAT Bangalore25 Oct 2024AY 2020-21

Bench: Shri Waseem Ahmed & Shri Keshav Dubeyassessment Years : 2020-21

For Appellant: Shri Vasant Kumar, CAFor Respondent: Shri V Parithivel, JCIT
Section 60Section 80P(2)Section 80P(2)(a)Section 80P(2)(d)Section 80P(4)

disallowed the same on the reasoning that the assessee was a cooperative bank and, therefore, it was hit by the provisions of section 80P(4) of the Act and thus would not be eligible for claiming deduction under section 80P(2) of the Act. Finally, the issue reached the Hon’ble Apex Court where it was held that banking

M/S. GMR ENTERPRISES PRIVATE LIMITED,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE- 2(2), BANGALORE

In the result, the appeal filed by the assessee is partly allowed

ITA 2310/BANG/2019[2015-16]Status: DisposedITAT Bangalore28 Oct 2021AY 2015-16

Bench: Shri George George K, Jm & Shri B.R.Baskaran, Am It(Tp)A No.2310/Bang/2019 : Asst.Year 2015-2016 M/S.Gmr Enterprises Pvt. Ltd. The Dy.Commissioner Of (Successor To Gmr Holdings P.Ltd) Income-Tax, Central Circle 2(2) V. Bangalore. No.25/1 Skip House, Museum Rd. Bangalore – 560 025. Pan : Aaccr1554R. (Appellant) (Respondent) Appellant By : Sri.Yogesh Thar, Ca Respondent By : Sri.Sumer Singh Meena, Cit-Dr Date Of Pronouncement : 28.10.2021 Date Of Hearing : 25.10.2021 O R D E R Per Bench:- This Appeal At The Instance Of The Assessee Is Directed Against Final Assessment Order Dated 14.10.20199 Passed U/S 143(3) R.W.S. 144C Of The I.T.Act. The Relevant Assessment Year Is 2015-2016. 2. The Assessee Has Raised Five Grounds & Various Sub Grounds. The Assessee By Its Application Dated 13.07.2020 Has Also Raised An Additional Ground. The Learned Ar During The Course Of Hearing Submitted That Grounds No.Ii & Iii May Be Adjudicated & The Other Grounds May Be Left Open. Therefore, Grounds No.Ii & Iii Are Reproduced Below:-

For Appellant: Sri.Yogesh Thar, CAFor Respondent: Sri.Sumer Singh Meena, CIT-DR
Section 142ASection 143(3)Section 14ASection 56(2)(viib)

disallowance u/s 14A of the I.T.Act to Rs.27,37,47,187. 3.8 In the result, ground No.II raised by the assessee is allowed. Ground No.III : Addition on account of share premium received u/s 56(2)(viib) of Rs.257,87,32,783/- 4. During the relevant assessment year, the assessee- company had allotted 1,51,740 shares

DCIT, CIRCLE 3(1)(1), BENGALURU, BMTC BUILDING, KORAMANGALA vs. GTR ALUMINIUM PRIVATE LIMITED, BENGALURU

In the result the appeal filed by the revenue is dismissed

ITA 165/BANG/2024[2015-16]Status: DisposedITAT Bangalore21 Nov 2025AY 2015-16

Bench: Shri Waseem Ahmed & Shri Keshav Dubeyassessment Year : 2015-16

For Appellant: Sri Monish Sowkhar, A.RFor Respondent: Sri Balusamy N., D.R
Section 143(3)Section 250Section 253Section 263Section 56(2)(viib)

X (PV/PE), Where, . . . . (b) the fair market value of the unquoted equity shares determined by a merchant banker or an accountant as per the Discounted Free Cash Flow method.” 10.2 After going through the above Rule we take note of the fact that the assessee had opted DCF method and got valuation report from an accountant as per the Rule

M/S. BHAVASAR KSHATRIYA CO-OPERATIVE CREDIT SOCIETY LIMITED,HUBBALLI vs. INCOME TAX OFFICER WARD-3(3), HUBBALLI

In the result, all the three appeals filed by assessee stands allowed for statistical purposes

ITA 581/BANG/2022[2015-16]Status: DisposedITAT Bangalore19 Oct 2022AY 2015-16

Bench: Smt. Beena Pillai & Shri Laxmi Prasad Sahuassessment Appeal No. Appellant Respondent Year The Income-Tax

For Appellant: Smt. Pratibha, Advocate
Section 56Section 57Section 80PSection 80P(2)(a)Section 80P(2)(d)

x) of clause (24) of section 2 which is chargeable to income-tax under the head "Income from other sources", deductions, so far as may be, in accordance with the provisions of clause (va) of sub-section (1) of section 36 ;] (ii) in the case of income of the nature referred to in clauses (ii) and (iii) of sub-section

M/S. BHAVASAR KSHATRIYA CO-OPERATIVE CREDIT SOCIETY LIMITED,HUBBALLI vs. ASSISTANT DIRECTOR OF INCOME TAX, CPC, BANGALORE

In the result, all the three appeals filed by assessee stands allowed for statistical purposes

ITA 583/BANG/2022[2019-20]Status: DisposedITAT Bangalore19 Oct 2022AY 2019-20

Bench: Smt. Beena Pillai & Shri Laxmi Prasad Sahuassessment Appeal No. Appellant Respondent Year The Income-Tax

For Appellant: Smt. Pratibha, Advocate
Section 56Section 57Section 80PSection 80P(2)(a)Section 80P(2)(d)

x) of clause (24) of section 2 which is chargeable to income-tax under the head "Income from other sources", deductions, so far as may be, in accordance with the provisions of clause (va) of sub-section (1) of section 36 ;] (ii) in the case of income of the nature referred to in clauses (ii) and (iii) of sub-section

M/S. BHAVASAR KSHATRIYA CO-OPERATIVE CREDIT SOCIETY LIMITED,HUBBALLI vs. INCOME TAX OFFICER WARD-1(1), HUBBALLI

In the result, all the three appeals filed by assessee stands allowed for statistical purposes

ITA 582/BANG/2022[2017-18]Status: DisposedITAT Bangalore19 Oct 2022AY 2017-18

Bench: Smt. Beena Pillai & Shri Laxmi Prasad Sahuassessment Appeal No. Appellant Respondent Year The Income-Tax

For Appellant: Smt. Pratibha, Advocate
Section 56Section 57Section 80PSection 80P(2)(a)Section 80P(2)(d)

x) of clause (24) of section 2 which is chargeable to income-tax under the head "Income from other sources", deductions, so far as may be, in accordance with the provisions of clause (va) of sub-section (1) of section 36 ;] (ii) in the case of income of the nature referred to in clauses (ii) and (iii) of sub-section

NAGAPURA CREDIT CO OPERATIVE SOCIETY,BANGALORE vs. INCOME TAX OFFICER, WARD-6(2)(2), BANGALORE

In the result, the appeal of the assessee is allowed for statistical purposes

ITA 224/BANG/2024[2017-18]Status: DisposedITAT Bangalore14 May 2024AY 2017-18

Bench: Smt. Beena Pillai & Shri Waseem Ahmed

For Appellant: Shri Gireesha T.L, C.AFor Respondent: Shri Muthu Shankar, Addl. CIT (DR)
Section 80PSection 80P(2)(a)Section 80P(2)(d)

disallowed the same on the reasoning that the assessee was a cooperative bank and, therefore, it was hit by the provisions of section 80P(4) of the Act and thus would not be eligible for claiming deduction under section 80P(2) of the ITA No.223 to 226/Bang/2024 Page 4 of 10 Act. Finally, the issue reached the Hon’ble Apex

NAGAPURA CREDIT CO OPERATIVE SOCIETY,BANGALORE vs. INCOME TAX OFFICER, WARD-6(2)(1) , BANGALORE

In the result, the appeal of the assessee is allowed for statistical purposes

ITA 223/BANG/2024[2016-17]Status: DisposedITAT Bangalore14 May 2024AY 2016-17

Bench: Smt. Beena Pillai & Shri Waseem Ahmed

For Appellant: Shri Gireesha T.L, C.AFor Respondent: Shri Muthu Shankar, Addl. CIT (DR)
Section 80PSection 80P(2)(a)Section 80P(2)(d)

disallowed the same on the reasoning that the assessee was a cooperative bank and, therefore, it was hit by the provisions of section 80P(4) of the Act and thus would not be eligible for claiming deduction under section 80P(2) of the ITA No.223 to 226/Bang/2024 Page 4 of 10 Act. Finally, the issue reached the Hon’ble Apex

NAGAPURA CREDIT CO OPERATIVE SOCIETY,BANGALORE vs. INCOME TAX OFFICER, WARD-6(2)(1), BANGALORE

In the result, the appeal of the assessee is allowed for statistical purposes

ITA 225/BANG/2024[2018-19]Status: DisposedITAT Bangalore14 May 2024AY 2018-19

Bench: Smt. Beena Pillai & Shri Waseem Ahmed

For Appellant: Shri Gireesha T.L, C.AFor Respondent: Shri Muthu Shankar, Addl. CIT (DR)
Section 80PSection 80P(2)(a)Section 80P(2)(d)

disallowed the same on the reasoning that the assessee was a cooperative bank and, therefore, it was hit by the provisions of section 80P(4) of the Act and thus would not be eligible for claiming deduction under section 80P(2) of the ITA No.223 to 226/Bang/2024 Page 4 of 10 Act. Finally, the issue reached the Hon’ble Apex

NAGAPURA CREDIT CO OPERATIVE SOCIETY,BANGALORE vs. INCOME TAX OFFICER, WARD-6(2)(1), BANGALORE

In the result, the appeal of the assessee is allowed for statistical purposes

ITA 226/BANG/2024[2020-21]Status: DisposedITAT Bangalore14 May 2024AY 2020-21

Bench: Smt. Beena Pillai & Shri Waseem Ahmed

For Appellant: Shri Gireesha T.L, C.AFor Respondent: Shri Muthu Shankar, Addl. CIT (DR)
Section 80PSection 80P(2)(a)Section 80P(2)(d)

disallowed the same on the reasoning that the assessee was a cooperative bank and, therefore, it was hit by the provisions of section 80P(4) of the Act and thus would not be eligible for claiming deduction under section 80P(2) of the ITA No.223 to 226/Bang/2024 Page 4 of 10 Act. Finally, the issue reached the Hon’ble Apex